The proposal represents another significant step in the implementation of the “Moving Ahead for Progress in the 21st Century” (MAP-21) reauthorization law’s project delivery reforms. Specifically, it allows for environmental impact statements (EISs) combined with records of decision (RODs) when there is little or no change between the documents. This ARTBA-supported reform is significant because both EISs and RODs can be voluminous. Allowing the combination of the two would significantly reduce paperwork without sacrificing any regulatory safeguards.

The agencies propose another reform advocated by ARTBA: eliminating the requirement of a written statement when a project will have no adverse environmental impacts and no “reasonable or prudent” alternative to the project exists.